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Anti-Bribery Policy

Introduction

Paradigm Shift Consulting Ltd has a zero-tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity, in all its business dealings and relationships. This policy sets out how we will implement and enforce effective systems to counter bribery. 

Purpose and scope of Policy 

This policy sets out the Company’s position on any form of bribery and corruption, and provides guidelines aimed at: 

  • Ensuring compliance with anti-bribery laws, rules, and regulations, not just within the UK but in any other country within which we may carry out business or in relation to which our business may be connected. 
  • Enabling employees and persons associated with Paradigm Shift Consulting to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent, and report any wrongdoing, whether by themselves or others. 
  • Providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with.  
  • Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

This policy applies to all permanent and temporary employees of Paradigm Shift Consulting Ltd, including any of its intermediaries, subsidiaries, or associated companies. It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of Paradigm Shift Consulting, including but not limited to:  

  • Directors 
  • Agency workers 
  • Casual workers 
  • Contractors 
  • Consultant 
  • Seconded staff 
  • Agents 
  • Suppliers 
  • Sponsors (“associated persons”) 

All employees and associated persons are expected to adhere to the principles set out in this policy. 

Legal obligations 

The UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage. 

It is an offence in the UK to:   

  • Offer, promise, or give a financial or other advantage to another person (i.e., bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct. 
  • Request, agree to receive, or accept a financial or other advantage (i.e., receive a bribe) for or in relation to improper conduct.
  • Bribe a foreign public official.

You can be held personally liable for any such offence. 

It is also an offence in the UK for an employee or an associated person to bribe another person while doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business. Paradigm Shift Consulting can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage. 

Policy statement 

All employees and associated persons are required to: 

  • Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction, in any part of the world in which they might be expected to conduct business.
  • Act honestly, responsibly and with integrity.
  • Safeguard and uphold the Company’s core values by always operating in an ethical, professional, and lawful manner.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside, or accounts created for the purposes of facilitating the payment or receipt of a bribe.  

We recognise that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is always expected of all employees and associated persons. If in doubt as to what might amount to bribery or what might constitute a breach of this policy, refer the matter to your line manager. 

For the Company’s rules and procedures in relation to the receipt of business gifts from third parties and corporate hospitality offered to or received from third parties, please refer to our Gifts & Hospitality Policy. It forms part of our zero-tolerance policy towards bribery and it should be read in conjunction with this policy. 

Responsibilities and reporting procedure 

It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this policy and to prevent, detect and report any suspected bribery or corruption in accordance with the procedure set out in the Company’s disclosures in the public interest policy.  

You must immediately disclose to your manager any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of Paradigm Shift Consulting. For the avoidance of doubt, this includes reporting your own wrongdoing. The duty to prevent, detect and report any incident of bribery and any potential risks rests equally with all employees and associated persons. 

Paradigm Shift Consulting encourages all employees and associated persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation and any resulting action can be undertaken swiftly.  

If you wish to report an instance or suspected instance of bribery you should make a Public Interest Disclosure, and guidance on how to do this can be found in our Whistleblowing Policy. Confidentiality will be maintained during the investigation to the extent that it is practical and appropriate in the circumstances.  

Sanctions for a breach of policy 

We are committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons. 

The Company will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future. 

Sanctions for breach 

A breach of any of the provisions of this policy will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal. As far as associated persons are concerned, a breach of this policy could lead to the suspension or immediate termination of any relevant contract, sub-contract or other agreement. 

Monitoring compliance 

The Company’s Director has lead responsibility for ensuring compliance with this policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the senior management of Paradigm Shift Consulting, who have overall responsibility for ensuring this policy complies with the our legal and ethical obligations. 

Examples of potential risks 

The following is a non-exhaustive list of possible issues which raise bribery concerns and which you should report in accordance with the reporting procedure set out above: 

  • A third-party insists on receiving a commission or fee before committing to signing a contract with the Company, or carrying out a government function or process for the Company. 
  • A third-party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made. 
  • A third-party requests an unexpected additional commission or fee to facilitate a service. 
  • A third-party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services. 
  • A third-party approaches you to carry out work independently for money transfer or payment in cash. 
  • You are offered an unusually lavish, extraordinary or excessive gift or hospitality by a third party. 
  • You receive an invoice from a third party that appears to be non-standard or extraordinary. 
  • The Company is invoiced for a commission or fee payment that appears large given the service stated to have been provided. 
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